2020 (8) TMI 885

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....PA SATHYANARAYANA For the Appellant :Mr. M. Swaminathan senior standing counsel assisted by Ms. V. Pushpa, standing counsel (taxes) For the Respondent : Mr. R. Venkatnarayanan ORDERJUDGMENT [T.S. SIVAGNANAM, J.] This appeal by the assessee under Section 260 A of the Income Tax Act, 1961 ('the Act' for brevity) is directed against the order dated 04.12.2019 passed by the Inco....

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...., learned senior standing counsel for the appellant / Revenue assisted by Ms.V.Pushpa, learned standing counsel for the Revenue and Mr.R.Venkatnarayanan, learned counsel for M/s.Subbaraya Aiyar and Padmanabhan, learned counsel for the respondent/assessee. 3. The short issue which falls for consideration is as to whether any perversity in the order passed by the Tribunal as pointed out by Mr.M.S....

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....prefer any appeal as against the order of the CIT(A), restricting the disallowance to Rs. 39,70,832/-. The Revenue was on appeal as against that portion of the order of the CIT(A), which did not consider the Revenue's case that is, in respect of their argument to make a disallowance of the entire 7.39 crores. 5. It is the argument of Mr.M.Swaminathan, learned standing counsel that the Tribu....

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....l as against the confirmation of disallowance under Section 14(A) at R.39,70,832/-. This is a statement of fact. The second facet of the finding is with regard to the Revenue's contention that CIT(A) erred in restricting the disallowance to only Rs. 39,70,832/-. The Tribunal considered the factual position and earlier order passed by the Tribunal in the assesse's own case and held that the....